G.R. No. A.M. No. 2005-08-SC. December 9, 2005.
Samuel R. Ruñez, Jr., Complainant, vs. Marybeth V. Jurado, Respondent.

FACTS

Complainant Samuel R. Ruñez, Jr., an employee of the Supreme Court, filed an administrative complaint against Dr. Marybeth V. Jurado, a Medical Officer IV at the Court’s clinic. The complaint stemmed from an incident on January 12, 2005, when Ruñez’s father, Samuel Ruñez, Sr., also a Court employee, visited the clinic complaining of dizziness. His vital signs were alarming, with a blood pressure of 210/100 mmHg. Dr. Jurado asserted that she instructed the nurse to administer Capoten to lower his blood pressure, informed him he needed hospital conduction, and had the ambulance placed on standby. However, Ruñez, Sr. left the clinic, stating he would look for a companion. Dr. Jurado waited and asked a nurse to look for him, but he could not be located. Ruñez, Jr. later found his father and took him to a private hospital, where he subsequently suffered a stroke and later passed away. The complainant alleged that Dr. Jurado was neglectful for merely advising hospitalization and allowing his father to leave without ensuring he used the available ambulance.

ISSUE

Whether or not respondent Dr. Marybeth V. Jurado is administratively liable for simple neglect of duty based on her actions following the medical emergency of Ruñez, Sr.

RULING

The Supreme Court En Banc dismissed the complaint and found Dr. Jurado not liable for simple neglect of duty. The Court accepted the factual findings of the investigating officer that Dr. Jurado provided proper emergency treatment by administering medication and arranging for ambulance standby. The legal logic centers on the definition of simple neglect of duty, which is the failure to give proper attention to a task expected of an employee. The Court held that while Dr. Jurado could have exhibited greater compassion by personally searching for the patient or immediately alerting his relatives, these actions were not part of her official duties as a physician in that context. Her core responsibilities—assessing the patient, providing emergency intervention, and ordering hospital conduction—were fulfilled. The patient’s voluntary decision to leave the clinic interrupted the planned course of action. Administrative liability requires a breach of a duty owed by virtue of one’s office. Since no expected task was left unperformed, the element of neglect was absent. The Court, however, exhorted all clinic personnel to strive for the highest standard of service.